Skip to content

UDAAP Violation?

Question: 
Can a bank be at risk for a UDAAP violation by offering an overdraft opt-in program?
Answer: 

A definitive answer depends on your program practices. The regulatory concern is that consumers who have opted-in to have their ATM and POS transactions paid but incur an overdraft fee are being treated unfairly in comparison to those who have not opted-in and are not charged if there are force-pay transactions.

Presumably, the agencies will be providing more guidance.

First published on 10/29/2012

Search Topics